UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTIONOF:

Daniels Elite Photography

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF Blade Chroma UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on June 23

th

, 2015 

Deontae L Daniels

Daniels Elite 

Photography

4061 Bluebird drive. 

Waldorf , MD 20603

Tel: (757) 613-3371
TABLE OF CONTENTS

Page 

GLOSSARY OF ABBREVIATIONS. ................................................................................. 3 

SUMMARY. ......................................................................................................................... 4

INTRODUCTION AND INTERESTS OF PETITIONER ....................................................4 

BACKGROUND.................................................................................................................... 4

BASIS FOR PETITION........................................................................................................ 5

NAME AND ADDRESS OF PETITIONER ............................................................ 7 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH DANIELS

PHOTOGRAPHY SEEKS EXEMPTION. ............................................................... 8 

THE EXTENT OF RELIEF Daniels Elite Photography SEEKS AND THE 

REASON DANIELS ELITE PHOTOGRAPHY SEEKS THE 

RELIEF.............. .................................................................................................. 11 

THE REASONS WHY GRANTING DANIELS PHOTOGRAPHY’S 

REQUEST WOULD BE IN THE PUBLIC INTEREST ......... ............................ 15 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY ......................................................................... 19 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERALREGISTER. .... 34 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT DANIELS ELITE PHOTOGRAPHY’S 

R ................................................................................................................................. 34 EQUEST...

CONCLUSION ................................................................................................................... 35

APPENDICES........................................................................................37 

2
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command 

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 

SO Safety Observer

SOP Standard Operating Procedures 

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

3
SUMMARY

Daniels Elite Photography seeks exemption from the requirements of 14 C.F.R §§ 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)

(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 

of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit 

Daniels Elite Photography to operate an Unmanned Aircraft System (UAS) for the 

commercial purpose of conducting aerial video and photography of construction sites, real 

estate, and landscape over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Daniels Elite Photography Continually provides its clients with expertise in the 

field of photography and videography. Daniels Elite Photography has worked with many 

clients on races, special events and weddings. Daniels Elite Photography is experienced in 

all aspects of videography and photography. The objective of Daniels Photography’s 

aerial video and photography Department is to provide high quality imaging for a variety 

of commercial and residential customers. Owner Deontae Lee Daniels has extensive 

knowledge with Model Aircrafts to include R/c Jets, helicopters and planes. currently a 

member of the AMA as well as the Charles County Remote Control Club located in 

Brandywine Maryland. 

Unmanned Aircraft Systems: Blade Chroma Camera Drone

UASs

Daniels Elite Photography seeks an exemption to operate Blade 

Chroma within the NAS. The Blade Chroma Camera Drone

Features are vertical takeoff and landing (VTOL) Unmanned Aircraft 

(UA) with a Ground Control Station (GCS) 

4
systems. The Blade Chroma Camera Drone has a maximum gross weight of 

approximately 3 pounds 9 ounces, while having a length of 16 inches width of 16 inches, 

height of 8 inches, and a maximum speedof approximately 29 knots. The UAs are 

equipped with four main rotors; driven by Lithium Polymer battery powered electric 

motors. 

The Blade Chroma Camera Drone UAs that will be operated by Daniels Elite 

Photography will be registered in accordance with 49 

U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, 

and markedin accordance with 14 C.F.R. Part 45, Identification and Registration Marking. 

BASIS FOR PETITION

Petitioner, Daniels Elite Photography, pursuant to the provisions of the Federal 

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 

2012 

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to commercially operate the Blade Chroma Camera 

DroneUASs in the National Airspace System (NAS), and for an exemption from the 

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

In consideration of the speed, weight, size, and limited operating area associated 

with the unmanned aircraft and its operation, Daniels Photography’s operation of 

5
Blade Chroma Camera Drone UASs meets the conditions of FMRA Section 333 and 

therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 

21, Subpart H. 

Daniels Elite Photography requests relief from Sections 91.405(a), 91.407(a)

(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth 

requirements for maintenance that only apply to aircraft with an airworthiness 

certificate. Daniels Elite Photography submits that the requested relief is proper since an 

equivalent level of safety will be ensured. Daniels Elite Photography will Only use 

experienced personnel or technicians to perform maintenance, alterations, or preventive 

maintenance on the UASs using the methods, techniques, and practices prescribed in the 

operating documents (i.e., Instruction Manual). Furthermore, Daniels Elite Photography

will document and maintain all maintenance records for the Blade Chroma Camera Drone

UASs. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private 

pilot privileges and limitations: Pilot in command, is requested by Daniels Elite 

Photography to the extent necessary to allow a Pilot in Command (PIC) and who has 

demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC 

is able to safely operate the Blade Chroma Camera Drone UASs in a manner consistent 

with this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

Daniels Elite Photography seeks relief from Section 91.7(a), entitled Civilaircraft 

6
airworthiness, because the Blade Chroma CameraUASs do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Daniels Elite 

Photography submits that it will ensure that the Blade Chroma Camera Drone UASs are 

in an airworthy condition, prior to every flight, by determining that the UASs are in 

compliance with the operating documents (i.e., Instruction Manual), and that the aircraft 

are in a condition for safe flight. 

Daniels Elite Photography also seeks an exemption from the requirements of 

Section 91.121, entitled Altimeter Settings, as the Blade Chroma Camera Drone UAs will 

not have a typical barometric altimeter onboard. However, altitude information of the 

Blade Chroma Camera Drone UAs will be provided to the PIC via Global Positioning 

System 

(GPS) equipment and radio communications telemetry data link, which downlinks from 

the UA to the GCS for active monitoring of the flight path. This altitude information, 

combined with Daniels Photography’s operation of the Blade Chroma Camera Drone 

UASs within visual line of sight, at or below 400 feet AGL, will ensure a level of safety 

equivalent to Section91.121. 

Additionally, Daniels Elite Photography seeks an exemption from the 

requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR 

conditions. Daniels Elite Photography submits that safety will not be affected by 

operation of the Blade Chroma Camera Drone UAs during daylight hours in visual 

meteorological conditions (VMC) under visual flight rules (VFR), with enough battery 

power to fly for a total 

7
duration of approximately 13.5 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 4.5 minutes. In accordance with 14 

C.F.R. § 11.81, Daniels Elite Photography provides the following information in support of 

its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is: 

Deontae L Daniels

Daniels Elite 

Photography

4061 Bluebird D rive Waldorf, MD 20603 Tel: 

(757) 613-3371

Email: 

DeontaeDaniels@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which Daniels Elite Photography 

Seeks Exemption.

1. Daniels Elite Photography Seeks Exemption From The

Requirements Of Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if— 

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

2. Daniels Elite Photography Seeks Exemption From The

Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the 

following: 

8
(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. Daniels Elite Photography Seeks Exemption From The

Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in 

part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set, 

when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of 

this section, the current reported altimeter setting of an appropriate 

available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting availablebefore

departure.

4. Daniels Elite Photography Seeks Exemption From The

Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly 

to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 20 minutes.

5. Daniels Elite Photography Seeks Exemption From The

Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: 

Each owner or operator of an aircraft— 

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter[.] 

9
6. Daniels Elite Photography Seeks Exemption From The

Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 

43.7 of this chapter[.] 

7. Daniels Elite Photography Seeks Exemption From The

Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following: 

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has 

been approved for return to service by a person authorized by § 43.7 of this

chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter.

8. Daniels Elite Photography Seeks Exemption From The

Requirements Of Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe)and

each engine, propeller, rotor, and appliance of an aircraft. The records must 

include--

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and

10
(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service.

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor.

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which

are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the 

aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is 

required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors,

propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after the 

work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service.

11
C.The Extent Of Relief Daniels Elite Photography Seeks And The Reason Daniels 

 Photography Seeks The Relief.

1. Extent Of Relief Daniels Elite Photography Seeks And The Reason

Daniels Photography Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a 

private pilot or higher level certificate, as well as a current and valid airman medical 

certificate, and who has met certain flight-hour and currency requirements, to conduct the 

proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b)

state that a private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if: (1) The flight is only incidental to that 

business or employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire.

As set forth more fully below, Daniels Elite Photography submits that an 

equivalent level of safety will be maintained because no PIC will be allowed to operate the 

UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating 

that the PIC is able to safely operate Blade Chroma UAS in a manner consistent with the 

operations specifications as described in this exemption, including evasive and emergency 

maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and 

structures. 

Daniels Elite Photography submits that all flights of the UASs, conducted 

by the PIC pursuant to the grant of this 

12
Petition: (1) will be incidental to Daniels Photography’s business; and (2) will not 

carry passengers or property for compensation or hire. 

2. Extent Of Relief Daniels Elite Photography Seeks And The

Reason Daniels Elite Photography Seeks Relief From Section

91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to 

the extent required to allow Daniels Elite Photography to determine that the UASs are 

in airworthy condition prior to every flight by ensuring that the UAS is in compliance 

with the operating documents (i.e., Instruction Manual). 

Daniels Elite Photography seeks the requested relief because the Blade Chroma 

UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. Therefore, Daniels Elite Photography will ensure that the Blade Chroma 

UASs are in airworthy condition based upon its compliance with the operating 

documents (i.e., Instruction Manual) prior to every flight, and further, determine that 

the aircraft are in condition for safe flight, as stated in the conditions and limitations 

below. 

3. Extent Of Relief Daniels Elite Photography Seeks And The Reason

Daniels Elite Photography Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to 

allow flight operations of the Blade Chroma 

13
UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio 

communications telemetry data link to downlink altitude information from the UA to the 

PIC at the ground control station (GCS). Since the FAA requires that any altitude

information concerning UAS operations be reported to air traffic control (ATC) in feet 

above ground level (AGL), Daniels Elite Photography seeks the requested relief 

because the Blade Chroma UA’s altimeter may be set on the ground to zero feet 

AGL, the local rather than barometric pressure or field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 

91.121 is sought to the extent necessary to comply with the applicable conditions and 

limitations stated below. As more fully set forth herein, an equivalent level of safety will 

be maintained since the Blade Chroma UAs are equipped with a barometric pressure 

sensor and GPS equipment, which automatically ensures that a ground level pressure 

setting will be established prior to each flight, and provides the PIC with altitude 

information of the UA on the heads-up display of the GCS. 

4. Extent Of Relief Daniels Elite Photography Seeks And The Reason

Daniels Elite Photography Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR 

conditions, is requested to the extent required to allow flights of the battery powered Blade 

Chroma UAs during daylight hours in visual meteorological conditions (VMC), under 

visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended 

landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. 

Daniels Elite Photography seeks the requested relief because without an exemption from 

Section 91.151(b), the flight time 

14
duration of the battery powered Blade Chroma UAs will severely constrain the 

practicality of any aerial video or still photo flight operations that Daniels Elite 

Photography proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the Blade Chroma

UASs, the Blade Chromaoperating documents, and Daniels Photography’s proposed 

operating limitations, ensure that Daniels Elite Photography will safely operate the 

battery powered UAs during daylight hours in visual meteorological conditions (VMC), 

under visual flight rules (VFR), with enough battery power to fly for a total duration of 

13.5 minutes to the first point of intended landing and, assuming normal cruising speed, 

to fly after that for at least 4.5 minutes. 

5. Extent Of Relief Daniels Elite Photography Seeks And The Reason

Daniels Elite Photography Seeks Relief From Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) 

only apply to aircraft with an airworthiness certificate, Daniels Elite Photography requests 

relief from these Sections because the UASs do not require airworthiness certificates. As 

set forth more fully below, the UASs meet the conditions of FMRA Section 333 for 

operation without an airworthiness certificate. Accordingly, Daniels Elite Photography

will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UASs using the methods, techniques, and practices prescribed in the 

UAS operatingdocuments (i.e., 

15
Instruction Manual). Daniels Elite Photography will document and maintain all 

maintenance records for the Blade Chroma Camera Drone UASs. 

D.The Reasons Why Granting Daniels Photography’s Request Would Be In 

The Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing 

Daniels Elite Photography to safely, efficiently, and economically perform aerial video 

and photography of construction sites, real estate, and landscape over certain areas of 

the United States. 

Additionally, use of the Blade Chrome Drone the NAS, reduce pollution, and 

provide significant benefits to the economy. Notably, the benefits of Daniels

Photography’s proposed operation of the Blade Choma Camera Drone UASs will be 

realized without implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The Blade Chroma UAs are battery powered and serve as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial 

imagery. By reducing the amount of manned aircraft needed to perform aerial 

acquisitions, an exemption allowing the use of a UAS would reduce the amount of 

manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety 

of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The

16
 UAs do not require an airport to takeoff or land. Likewise, a reduction of manned 

aircraft conducting aerial video and photography missions would result in fewer aircraft 

that must be handled by air traffic control during the ground, takeoff, departure, arrival, 

and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The

Blade Chroma Camera Drone UASs.

Conducting aerial acquisitions with the Blade Chroma Camera Drone UASs, 

instead of manned aircraft, will greatly benefit the public by drastically reducing the levels 

of air and noise pollution generated during traditional aerial video and still photography 

flight operations. By using battery power and electric motors, the Blade Chroma Camera 

Drone UASs produce no air pollution, and is the most 

viable environmentally conscious alternative to the cabin class, six cylinder internal 

combustion engine aircraft that are typically utilized for aerial video andphotography, 

while burning approximately 20-30 gallons per hour of leaded aviation fuel. The Blade 

Chroma Camera Drone , while reducing the carbon footprint of aerial acquisitions, also 

eliminates noise pollution, as the UAs are propelled by battery powered electric motors, 

rather than an internal combustion engine. 

By using the UASs to perform aerial acquisitions, the substantial risk to life and 

property in the air and on the ground, which is usually associated with traditional manned 

aircraft flight operations, will be substantially reduced or completely eliminated. Aside 

from the lack of flight crew members located onboard the aircraft, the Blade Chroma 

Camera Drone 

17
at only 3 pounds has less physical potential for collateral damage to life and property on 

the ground, and in the air, compared to the manned aircraft that typically conduct similar 

operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 

feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The

Blade Chroma Camera Drone UASs Will Benefit The Economy.

In addition to being safe and efficient, the Blade Chroma Camera Drone UASs 

are also an economical alternative to using manned aircraft to conduct similar aerial 

operations. As such, operation will allow United States based companies, like Daniels 

Elite Photography, to remain competitive and contribute to growth of the U.S. 

economy. Specifically, with the rising cost of aviation fuel and the Environmental 

Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels.

18
4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, Daniels Photography’s proposed operation of the Blade Chroma Camera Drone 

UASs will not implicate any privacy issues. Specifically, UASs will be operated only in 

compliance with operating documents (i.e., Instruction Manual) which requires property 

owner involvement as well as local law enforcement notification, and in accordance with 

the Federal Aviation Regulations, including the minimum altitude requirements of 14 

C.F.R. § 91.119. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, 

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That 

Provided By The Rule From Which Daniels Elite Photography Seeks Exemption.

1. Reasons Why The Blade Chroma Camera Drone UAs Meet The Conditions

Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated 

with the unmanned aircraft and its operation, DanielsPhotography’s operation of the

Blade Chroma Camera Drone UASs meet the conditions of FMRA Section 333, and will 

not require an airworthiness certificate in 

19
accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security.

Specifically, FMRA Section 333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not 

later than 180 days after the date of enactment of this Act, the Secretary of 

Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the plan 

and rulemaking required by section 332 of this Act or the guidance required by 

section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their 

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create 

a hazard to users of the national airspace system or the public or pose a 

threat to national security; and

(2) ) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines underthis 

section that certain unmanned aircraft systems may operate safely in the

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system.

In seeking this exemption, Daniels Elite Photography submits that the 

Blade Chroma Camera Drone UASs can operate safely in the 

NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the 

Blade Chroma Camera Drone UASs; (b) the pilot 

certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The Blade Chroma Camera Drone UASs

Demonstrate Its Safe Characteristics.

20
The Blade Chroma Camera Drone UASs do not create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security considering its size, 

weight, speed, and operational capability. 

i. Technical Specifications Of The UASs.

The technical specifications of the Blade Chroma Camera Drone are set forth by 

the , Blade Chroma Camera Drone Specifications and Data Sheet, attached here to as 

Exhibit A 

iii. The Blade Chroma Camera Drone UASs Are Designed For

Automatic Return To Home Point Or Hover In The Event Of

Loss Of The Control Link Or Navigation.

When the Control Link is lost, the Blade Chroma Camera Drone UAs will remain 

stationary, in flight, for 3 seconds or more. If, after 3 seconds, UAs do not reacquire 

control link data from the GCS, the UAs will assume that the Control Link is lost and the 

UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the 

takeoff position and shutdown. 

21
b. Flight Operations Of Blade Chroma Camera Drone UASs Are Limited

To The Line Of Sight Of A Certificated Pilot in Command With A

Safety Observer.

Daniels Elite Photography will only utilize certificated pilots to act as a 

pilot in command (PIC) of the Blade Chroma Camera Drone UASs. Additionally, 

a safety observer will assist all pilots during flight time. 

c. Flights Of Blade Chroma Camera Drone UASs Will Be

Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Daniels Elite Photography proposes to commercially 

operate Blade Chroma Camera Drone UASs for the special purpose of conducting aerial 

video and photography over certain areas of United States, pursuant to the following 

specific operating limitations: 

1. Operations authorized by this grant of exemption will be limited to the following

aircraft described in the operating documents, rotorcraft UASs weighing less

22
than 55 pounds maximum gross weight: Blade Chroma Unmanned Aircraft 

Systems. Proposed operations of any other aircraft will require a new petition 

or a petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations

for the purpose of aerial video and photography.

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground

level (AGL), as indicated by the procedures specified in the operating

documents unless a special request is made and approved by ATC. All altitudes

reported to ATC must be in feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all

times. This requires the PIC to be able to use human vision unaided by any

device other than corrective lenses, as specified on the PIC’s FAA-issued airman

medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not

permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy

the VLOS requirement as long as the PIC always maintains VLOS capability. The

SO and PIC must be able to communicate verbally at all times. Electronic

messaging or texting is not permitted during flight operations. The PIC must be

designated before the flight and cannot transfer his or her designation for the

duration of the flight. The PIC must ensure that the SO can perform the

functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing

and avoiding other air traffic and other ground based obstacles/obstructions and

is not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during

UAS operations and made available to the Administrator upon request. If a

discrepancy exists between the conditions and limitations contained in the grant

of exemption and the procedures outlined in the operating documents, the

conditions and limitations contained in the grant of exemption take precedence

and must be followed. Otherwise, the operator must follow the procedures as

outlined in its operating documents. The operator may update or revise its

operating documents. It is the operator’s responsibility to track such revisions

and present updated and revised documents to the Administrator upon request.

The operator must also present updated and revised documents if it petitions for

extension or amendment to the grant of exemption. If the operator determines

that any update or revision would affect the basis upon which the FAA granted

the exemption, then the operator must petition for amendment to its grant of

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if

questions arise regarding updates or revisions to the operating documents.

23
10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a

condition for safe flight. If the inspection reveals a condition that affects the

safe operation of the UAS, the aircraft is prohibited from operating until the

necessary maintenance has been performed and the UAS is found to be in a

condition for safe flight. The Ground Control Station must be included in the

preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS

operation or flight characteristics, e.g. replacement of a flight critical

component, must undergo a functional test flight. The PIC who conducts the

functional test flight must make an entry in the aircraft records.

12. The pre-flight inspection must account for all potential discrepancies, e.g.

inoperable components, items, or equipment, not already covered in the

relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component,

maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. Maintenance,

inspection, alterations, and status of replacement/overhaul component parts must

be noted in the aircraft records, including total time in service, description of

work accomplished, and the signature of the authorized person returning the

UAS to service.

15. Each UASs operated under this exemption must comply with all manufacturer

Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the

corrective action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current

third- class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meetsthe

operator’s qualification criteria and demonstrates the ability to safely operate the

UAS in a manner consistent with how the UAS will be operated under the

exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from persons, vessels, vehicles and structures. PIC

qualification flight hours must be logged in a manner consistent with 14 C.F.R.

§ 61.51(b). Flights for the purposes of training the operator’s PICs are permitted

under the terms of the exemption. However, training operations may only be

conducted during dedicated training sessions. During training, proficiency, and

experience-building flights, all persons not essential for flight operations are

considered nonparticipants, and the PIC must operate the UA with appropriate

distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. §

24
19.1. All operations must be conducted under visual meteorological 

conditions (VMC). If flight at night is required, a special request will be made at 

the FAA office closest to proposed area of operations. Flights under special 

visual flight rules (SVFR) are not authorized. 

20. The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA-published aeronautical chart unless a letter of

agreement with that airport’s management is obtained, and the operation is

conducted in accordance with a NOTAM as required by the operator’s COA. The

letter of agreement with the airport management must be made available to the

Administrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the

PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered

in accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or

emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and

forecast weather conditions) there is enough power to fly at normal cruising

speed to the intended landing point and land the UA with 25% battery power

remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate

of Waiver or Authorization (COA) prior to conducting any operations under the

grant of exemption. This COA will also require the operator to request a Notice

to Airman (NOTAM) not more than 72 hours in advance, but not less than 48

hours prior to the operation. All operations shall be conducted in accordance

with airspace requirements in the ATO issued COA including class of airspace,

altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by

serial number, registered in accordance with 14 C.F.R. part 47, and have

identification (N- Number) markings in accordance with 14 C.F.R. part 45,

Subpart C. Markings must be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation

and control of the UA must comply with the Federal Communications

Commission (FCC) or other appropriate government oversight agency

requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be

available to the PIC at the Ground Control Station of the UAS any time the

UAS is operating. These documents must be made available to the

Administrator or any law enforcement official upon request.

25
29. The UA must remain clear and yield the right of way to all manned aviation

operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating

persons (persons other than the PIC, SO, operator trainees or essential persons),

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

persons from the UA and/or debris in the event of an accident. The

operator must ensure that nonparticipating persons remain under such

protection. If a situation arises where nonparticipating persons leave such

protection and are within 500 feet of the UA, flight operations must cease

immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the

owner/controller of such vessels, vehicles or structures has granted

permission and the PIC has made a safety assessment of the risk of

operating closer to those objects and determined that it does not present

an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons

do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled-access property

with permission from the land owner/controller or authorized representative.

Permission from land owner/controller or authorized representative will be

obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or

vertical boundaries of the operational area as defined by the applicable COA

must be reported to the FAA's UAS Integration Office (AFS-80) within 24

hours. Accidents must be reported to the National Transportation Safety Board

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a)

And (b) Would Not Adversely Affect Safety.

Daniels Elite Photography submits that the equivalent level of safety 

established by Section 61.113(a) and (b) will be maintained because no PIC will be 

allowed to operate the Blade Chroma Camera Drone UASs unless that PIC has 

demonstrated, by meeting minimum flight-hour requirements, and is able to safely 

operate the Blade Chroma Camera Drone 

26
in a manner consistent with the exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from people, vessels, vehicles and structures. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to 

UAS, in circumstances similar, in all material respects, to those presented herein (e.g.

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). 

Daniels Elite Photography will not allow any PIC to operate the UAS in a 

manner consistent with this exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from people, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent 

27
with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a 

minimum of 5 hours of those hours as a UAS pilot operating the same make and model of 

UAS to be used for operations under the exemption). In addition to the hour requirements, 

the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency 

purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight

experience that was obtained in compliance with applicable regulations will ensure an

equivalent level of safety during Daniels Elite Photography’s proposed operations. The 

Administrator has held that prior documented flight experience that was obtained in 

compliance with applicable regulations would ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for 

the purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of 

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

operating the same make and model of UAS to be used for operations under the 

exemption. For clarification, the FAA considers these minimum hour requirements

to be inclusive rather than additive; i.e. 5 hours make and model time may be 

included in the 10 hours of multi-rotor time and the 10 hours may be included in 

the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the 

PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for

currency purposes). The FAA finds that at a minimum, the flight-hour requirements 

in Exemption No. 11062 are appropriate to practice and build proficiency in the 

skills necessary to safely conduct the petitioner’s proposed operations. The FAA 

also finds that prior documented flight experience that was obtained in compliance 

with applicable regulations would satisfy this requirement. Training, proficiency, 

and experience-building flights can also be conducted under the grant of exemption 

to accomplish the required flight time. During training, proficiency, and

experience-building flights the PIC is required to operate the UA with appropriate 

distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, Daniels Elite Photography will ensure safe operations by not allowing 

any PIC to operate the Blade Chroma Camera Drone 

28
UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency 

requirements, that the PIC is able to safely operate the Blade Chroma Camera Drone 

UAS in a manner consistent with the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a)

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained 

because prior to every flight, Daniels Elite Photography will ensure that the Blade 

Chroma Camera Drone UAS is in an airworthy condition based upon the UAS’s 

compliance with its operating documents and as stated in the conditions and limitations 

herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific 

to UAS, in circumstances similar, in all material respects, to those presented herein (e.g.

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the Blade Chroma Camera Drone UAs will be 

provided to the PIC via GPS equipment and a radio communications telemetry data link, 

which downlinks from the UA to the GCS for active monitoring of the flight path and 

altitude. This altitude information, combined with Daniels Photography’s operation of 

the Blade Chroma Camera Drone UAs within visual line of sight, at or below 500 feet 

AGL, 

29
will ensure a level of safety equivalent to Section 91.121. The altitude information will be 

generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero 

altitude initiation point is automatically established by the UASs at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b)

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the Blade 

Chroma Camera Drone UASs; (2) the limitations on the proposed flight operations; and (3) 

the location of the proposed flight operations. Accordingly, Daniels Elite Photography will 

ensure that it will safely operate the battery powered Blade Chroma Camera Drone UAs 

during daylight hours in VFR conditions, with enough battery power to fly for a total 

duration of 13.5 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 4.5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the Blade Chroma 

Camera Drone UASs; the limitations on the proposed flight operations; and the location of 

the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. 

Section 91.151(b). Furthermore, safety will be ensured as the Blade Chroma Camera 

Drone UASs provide audible and visual warnings to the PIC at the GCS when the UAs 

experiences low battery voltage, the first warning occurring at approximately 33% 

30
remaining battery power, and again at approximately 10% remaining battery power. At 

the critically low battery level, the Blade Chroma Camera Drone UASs will descend and 

land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristicsand

operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief 

from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would

Not Adversely Affect Safety.

In seeking this exemption, Daniels Elite Photography submits that the equivalent 

level of safety with regard to the regulatory maintenance and alteration requirements 

established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b) will be met because Daniels Elite Photography will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UASs using the methods, 

techniques, and practices prescribed in the operating documents (i.e., Instruction Manual). 

Furthermore, Daniels Elite Photographywill document and maintain all maintenance 

records for the Blade Chroma Camera Drone UASs. 

31
Since the Blade Chroma Camera Drone UASs will be inspected as prescribed by 

the operating documents, Daniels Elite Photography will maintain the equivalent level of 

safety established by Sections 

91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the Blade Chroma Camera Drone 

User Manuals are 

attached here as Exhibit B . 

Likewise, the exemption sought will not adversely affect safety because 

Daniels Elite Photography will use trained technicians to perform maintenance, 

alterations or preventive maintenance on the UAS using the methods, techniques, 

and practices prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 

Blade Chroma Camera Drone UASs will be performed by trainedtechnicians. 

Maintenance will be documented and maintained utilizing the monthly maintenancelog. 

Significantly, previous exemptions granted by the FAA concerning Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is

not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered.

In consideration of Daniels Photography’s proposed operating limitations, the 

operating documents, and the technical aspects of the Blade Chroma Camera Drone 

UASs, Daniels Elite Photography submits that safety will not be adversely affected by 

granting exemption from 14 C.F.R. Sections 

32
91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has 

previously granted relief specific to UAS in circumstances similar, in all material respects, 

to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Daniels Elite Photography

requests that the FAA prescribe special conditions for the intended operation of the Blade 

Chroma Camera Drone UASs, which contain such safety standards thatthe Administrator 

finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 

21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such 

special conditions will permit safe operation of the UAs for the limited purpose of 

conducting aerial video and photography over certain areas of the United Statesfor 

compensation or hire. FMRA Section 333 sets forth the requirements for considering 

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a 

threat to national security; and further, provides the authority for such UAS to operate 

without airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. 

§ 21.16, for operation of the Blade Chroma Camera Drone

UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain 

33
adequate or appropriate safety standards, due to the novel or unusual design features of 

the aircraft. Section 21.16, entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller

because of a novel or unusual design feature of the aircraft, aircraft engine or 

propeller, he prescribes special conditions and amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller as the 

FAA finds necessary to establish a level of safety equivalent to that established in 

the regulations. 

See 14 C.F.R. § 21.16. 

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA

may prescribe special conditions for Daniels intended operation of the 

Blade Chroma Camera Drone UASs, which 

contain such safety standards that the Administrator finds necessary to establish a level of

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R 

Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (a)(2), and 91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which Daniels Elite Photography Seeks Exemption:

Daniels Elite Photography seeks exemption from the requirements of 14 

C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Daniels Elite

Photography Seeks:

This exemption will permit Daniels Elite Photography to commercially operate 

an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video 

and photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support 

Daniels Photography’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

34
(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain 

UAS may operate safely in the NAS. As such, Daniels Photography’s request for 

exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. 

Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will 

create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security; and further, provides the authority for such UAS to operate without airworthiness 

certification.

As discussed in detail above, Daniels Elite Photography will operate the 

Blade Chroma Drone UASs safely in the NAS, without creating a hazard to 

users of the NAS, or the public, or otherwise pose a threat to national security. 

CONCLUSION

As set forth herein, Daniels Elite Photography seeks an exemption pursuant to 14

§ 11.61 and Section 333 of C.F.R. the FAA Modernization and Reform Act of 2012

(FMRA), which will permit safe operation of the Blade Chroma Camera Drone UASs 

commercially, without an airworthiness certificate, for the limited purpose of conducting 

aerial video and photography over certain areas of the United States. By granting this 

Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA 

Modernization and Reform Act of 2012, while also advancing the interests of the public, 

by allowing Daniels Elite Photography to safely, efficiently, and economically operate the 

Blade Chroma Camera Drone UASs commercially within theNAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA

35
Modernization and Reform Act of 2012, Section 333, Daniels Elite Photography

respectfully requests that the Administrator grant this Petition for an exemption from the 

requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Daniels Elite 

Photography to operate the Blade Chroma Camera Drone UASs commercially for the 

purpose of conducting aerial video and photography over certain areas of the United 

States. 

Dated: June 23th, 2015 

Respectfully submitted, 

Daniels Elite 

Photography /s/ 

Deontae Lee Daniels 

4061 Bluebird Dr, MD

20603 (757) 613-3371

Appendices: 

A. Blade Chroma Camera Drone Specifications Data 

B. Blade Chroma Camera Drone Manual

C. Monthly Maintenance Log

36
APPENDIX – A 

Blade Chrome Drone Log + TECHNICAL 

SPECIFICATIONS

Daniels Elite Photography only utilizes safe and reliable UASs. Horizon Hobby is an 

industry leader in small UAS production. Horizon Hobby's Blade Line of UASs are 

loaded with ground breaking software enabling the user to set parameters which will not 

allow flight into controlled airspace. Parameters 

can also be set to limit flight to no higher than a predetermined and set altitude as well 

as limit flight to a predetermined and set distance. In addition, Blade software provides 

real-time altitude and location information to the PIC via the linked monitor 

"SAFE Plus technology gives you several flight modes that have been specially 

programmed to make smooth, steady image capture easy. In fact, it can make you look 

like a pro even if you’ve never flown a camera drone before! All flight modes feature 

self-leveling and use GPS and altitude sensors to precisely hold position. SAFE Plus 

technology will even land the aircraft for you if you activate the Return Home function.

This version of the Chroma drone gives you the added benefit of Follow Me and 

Watch Me flight modes that let you focus on getting the shot while the drone does the 

flying."

"Return Home

Safe landings with the flip of a switch.

Returns the drone to its start-up point and lands it for you

Great for first-time flyers who aren’t ready to land themselves

Easy way to regain visual contact if you lose sight in flight

Resume full control at any time

Activates automatically if controller signal is lost

Adjustable Flight Boundaries

Stay legal. Stay safe. Fly responsibly.

Keeps the drone within altitude and distance limits you define

Easily adjusted using the Chroma programmer

Helps you avoid sensitive airspace ...and neighbors"
Aircraft Motor to Motor Distance: 15.7 in (400mm)

Rotor Type: Quadcopter

Prop Diameter: 10.2 in (260mm)

Approximate Flight Time: 30 minutes

Battery: 11.1V 3S 5400mAh Li-Po

Height: 9.50 in (242mm)

Weight: 45.9 oz (1.3 kg)

Motor Type: 4 × 780Kv Brushless Outrunner

Control Link: 2.4GHz

Video Link: 5.8GHz

Video Link Range: 1,970 ft (600m)

Satellite Navigation System: GPS, GLONASS

Completion Level: Ready-to-Fly

Camera

Operating Environment Temperature 0°C-40°C

Sensor Size

1/2.3" 

Effective Pixels

14 Megapixels 

Resolution

4384×3288 

HD Recording

1080p30 & 720p 

Recording FOV

110° / 85° 

Remote Control

Operating Frequency

5.728 GHz-5.85 GHz

Communication Distance (Open Area)

CE Compliance: 400m; FCC Compliance: 800m

Receiver Sensitivity (1%PER)

-93dBm 

38
APPENDIX – B

Blade Chroma Manufacturer’s User Manual 

*See attached PDF File

39
APPENDIX – C

Monthly Maintenance Log

UAS #_____ Date Issue Mantainence 

Performed

Initials

Firmware 

Check

Frame

Engines

Propellers

Camera

Gimbal

Landing 

Gear

Vibration

Other:

40